Principles of taxation law 2008

Covers the fundamental principles of the Australian tax system, providing students with guidance on reading and using tax resources such as legislation, case law and Australian Taxation Office rulings -- Back cover.

Principles of taxation law [2nd Ed.]

"With its clear and concise explanations of taxation law concepts, Principles of Taxation Law 2009 is the ideal text for students studying this complex subject. It covers all major topics underpinning the Australian tax system, including income, deductions, capital gains, tax accounting, international issues, fringe benefits, tax administration, goods and services tax and, in this new edition, offsets and superannuation. Importantly, the book commences with a special chapter on how to study tax law and succeed in taxation law exams."--Publisher description.

Principles of taxation law 2011 [4th ed.]

Taxation law can be an incredibly complex subject to absorb, particularly when time is limited. Written specifically for students, Principles of Taxation Law 2011 brings much needed clarity to this area of law -- Back cover.

The taxation of international maritime leasing profits : has the commissioners ship come in?

In light of McDermott Industries (AUST) Pty Ltd v Commissioner of Taxation, and Draft Taxation Ruling TR 2006/D8, this article considers the current Australian taxation position of profits arising from the cross-border leasing of vessels in the maritime industry. It focuses on the tax treaties to which Australia is a party, in particular the application of the business profits provisions of those treaties, and the deemed existence of a permanent establishment where substantial equipment, owned by a fiscal non-resident, is used within Australian waters.

Judicial and legislative considerations in the taxation of compensation receipts : an international comparison

In 1995, the Federal Commissioner of Taxation released Taxation Ruling TR 95/35 in an attempt to comprehensively address the appropriate capital gains tax treatment of a receipt of compensation, awarded either by the courts or via a settlement. The ruling was in response to the numerous, somewhat contradictory, court decisions of the early 1990s. Despite the release of TR 95/35, there still appears to be a lack of consensus as to the appropriate treatment of such awards. It has been suggested that the only way a taxpayer can, with any certainty, determine their liability is to obtain a private binding ruling, a far from satisfactory situation. In an attempt to clarify what the capital gains tax consequences of a compensation receipt should be, this article examines the Australian position and explores the comparative jurisprudence of the United Kingdom and Canada to ascertain whether the Australian attitude is consistent with these international jurisdictions. This article concludes that while the jurisdictions, through differing approaches, achieve a similar result, there is still a need to address the uncertainties that remain.

Unitary taxation : The case for global formulary apportionment

Unitary taxation is the taxation of the worldwide income of a multinational enterprise (MNE) and is normally based on a formulary apportionment method, which allocates income to the relevant jurisdictions based on a percentage of the MNE's world-wide profits. The unitary taxation model has several advantages over the existing arm's length model: 1. Where MNEs are highly integrated, unitary taxation has greater consistency with economic reality. 2. Greater certainty is provided to taxpayers. 3. Unitary taxation conforms to the aim of efficient operations within the MNE. 4. The aim of unitary taxation, to find an equitable split of profits between the jurisdictions, should ultimately be the overall aim of any tax regime. The advantages and disadvantages associated with the adoption of a unitary taxation model through the implementation of a formulary apportionment approach to the taxation of MNEs are examined.

Improved Subject Identification in Surveillance Video using Super Resolution

The time consuming and labour intensive task of identifying individuals in surveillance video is often challenged by poor resolution and the sheer volume of stored video. Faces or identifying marks such as tattoos are often too coarse for direct matching by machine or human vision. Object tracking and super-resolution can then be combined to facilitate the automated detection and enhancement of areas of interest. The object tracking process enables the automatic detection of people of interest, greatly reducing the amount of data for super-resolution. Smaller regions such as faces can also be tracked. A number of instances of such regions can then be utilized to obtain a super-resolved version for matching. Performance improvement from super-resolution is demonstrated using a face verification task. It is shown that there is a consistent improvement of approximately 7% in verification accuracy, using both Eigenface and Elastic Bunch Graph Matching approaches for automatic face verification, starting from faces with an eye to eye distance of 14 pixels. Visual improvement in image fidelity from super-resolved images over low-resolution and interpolated images is demonstrated on a small database. Current research and future directions in this area are also summarized.

An examination of recent taxation amendments, corporate law reforms and Queensland legislative reforms affecting nonprofit organisations

There is a tax amendment bill which will be debated. The Government has promised to outline its plan for the reform of the taxation system sometime this year. The plans appear to go beyond the mere introduction of some sort of goods and services tax to reform of the whole taxation system including fiscal relations with the States. Not for profit organisations will find their taxation environment will change. Governments are reluctant to permit exemptions to a GST style arrangements. GST trade offs such as reduced income tax rates and abolishing indirect taxes are useless to nonprofit organisations, as many are already exempt from such imposts. Administrative changes to tax collections may also have an impact. If the government decides to make an individual PAYE taxpayer return optional in exchange for no or standard deductions, this may have an effect on fundraising. The FBT and salary packaging schemes that not for profit organisations use will be under intense scrutiny. A regionalisation of the ATO along the successful model of the ASC would see discrete areas such as not for profit exemptions being centralised in one regional office for the whole of Australia. For example the Tasmanian ASC Office has the responsibility for much work in respect of corporate charities and not for profit companies.

Mobile multimedia : user and technology perspectives

As multimedia-enabled mobile devices such as smart phones and tablets are becoming the day-to-day computing device of choice for users of all ages, everyone expects that all mobile multimedia applications and services should be as smooth and as high-quality as the desktop experience. The grand challenge in delivering multimedia to mobile devices using the Internet is to ensure the quality of experience that meets the users' expectations, within reasonable costs, while supporting heterogeneous platforms and wireless network conditions. This book aims to provide a holistic overview of the current and future technologies used for delivering high-quality mobile multimedia applications, while focusing on user experience as the key requirement. The book opens with a section dealing with the challenges in mobile video delivery as one of the most bandwidth-intensive media that requires smooth streaming and a user-centric strategy to ensure quality of experience. The second section addresses this challenge by introducing some important concepts for future mobile multimedia coding and the network technologies to deliver quality services. The last section combines the user and technology perspectives by demonstrating how user experience can be measured using case studies on urban community interfaces and Internet telephones.

Measuring reef complexity and rugosity from monocular video bathymetric reconstruction

Topographic structural complexity of a reef is highly correlated to coral growth rates, coral cover and overall levels of biodiversity, and is therefore integral in determining ecological processes. Modeling these processes commonly includes measures of rugosity obtained from a wide range of different survey techniques that often fail to capture rugosity at different spatial scales. Here we show that accurate estimates of rugosity can be obtained from video footage captured using underwater video cameras (i.e., monocular video). To demonstrate the accuracy of our method, we compared the results to in situ measurements of a 2m x 20m area of forereef from Glovers Reef atoll in Belize. Sequential pairs of images were used to compute fine scale bathymetric reconstructions of the reef substrate from which precise measurements of rugosity and reef topographic structural complexity can be derived across multiple spatial scales. To achieve accurate bathymetric reconstructions from uncalibrated monocular video, the position of the camera for each image in the video sequence and the intrinsic parameters (e.g., focal length) must be computed simultaneously. We show that these parameters can be often determined when the data exhibits parallax-type motion, and that rugosity and reef complexity can be accurately computed from existing video sequences taken from any type of underwater camera from any reef habitat or location. This technique provides an infinite array of possibilities for future coral reef research by providing a cost-effective and automated method of determining structural complexity and rugosity in both new and historical video surveys of coral reefs.

Taxation of multinational banks : using formulary apportionment to reflect economic reality

The taxation of multinational banks is currently governed by general principles of international tax. However, there are characteristics exclusive to multinational banks that may warrant consideration of a separate taxing regime, as the current system does not produce a result that accurately reflects the economic source of the income or the location of the economic activity. The suggested alternative is unitary taxation using global formulary apportionment.

Nonprofit organisations and value added (GST) taxation

The subject of this paper is the changes in the taxation of non-profit organisations which seem to be more or less inherent in the value added taxes. The Australian federal Coalition's proposed goods and services tax will be part of the discussion.